Document dnEGOnwQmdxJMJr4v6Kgad0K6

A To: Dave Mahler From: Joe Ledvina Date: February 8, 1991 Subject: Part-time Benzene Service Dave, I found no specific exclusion for equipment that contains benzene a small percentage of the time. I vaguely remember talk of a cutoff for equipment that contains benzene less than 10% of the time but have not been able to substantiate that. We discussed this back when the Benzene Fugitive NESHAP was promulgated. Item 2 of my April 29, 1983 memo (attached) speaks to the issue. This is based on a conversation I had with Fred Dimmick on April 28, 1983. I think this position is still reasonable and recommend we continue to abide by it. Give me a call if you want to discuss. o 000098019